Privacy Policy

Introduction

Based in Wendover, Buckinghamshire, Joy Limited is a wholesaler of Moroccanoil haircare products. In order to provide our customers with the highest level of customer service we will need to collect and process personal data. This document explains how we go about this important aspect of our business, and in a way that you would expect protects your personal data and privacy whilst recognising the requirements of the latest legislation.

Please read this document carefully as it contains important information for you.

Why we collect personal data

Joy Limited needs to collect and process personal data like yours so that we can:

Deliver the services we have agreed with you as our customer;
Ensure the effective running of our business;
Meet our legal obligations, such as with financial records;
Manage and train our staff; and
Carry out our own marketing to develop and grow the business, for example sending out newsletters with details of new products.

In terms of the services we provide to you as our customer, these will include, for example, contacting you when necessary about any order, and billing you for any purchases.

Joy Limited collects personal data directly, for example, from our customers, suppliers, associates, business contacts and staff in the course of our normal business activities. Joy Limited believes it can process the personal data it collects because it:

Has obtained the necessary consent in an appropriate manner as needed;
Is necessary for the development and delivery of a contract or agreement to supply specific goods and services to a customer;
Is needed to comply with a legal obligation faced by the business; or
Is carried out as a legitimate interest of the business, such as its own marketing practices.

The data protection legislation allows businesses to process personal data where they have a legitimate business interest. Businesses that rely on this option are responsible for ensuring that the processing of that personal data does not put the individual or their rights at risk. Joy Limited believes it can rely on such interests in a number of situations. Examples of what we believe are a legitimate interest are:

To maintain an on-going relationship with our suppliers and other professionals such as our associates;
The marketing of our business;
The maintenance of a suppression list to ensure the rights of data subjects are met;
To perform due diligence on candidates for employment;
To protect our business from any possible legal actions; and/or
To carry out mystery shopping activities in accordance with our role as an authorised distributor.

We have carried out legitimate business assessments (LIAs) as outlined in the guidance issued by the Information Commissioner’s Office (ICO). We will review these assessments as part of our annual review on our approach to protecting personal data.

Where Joy Limited has sought your specific consent to process your personal data, you have the right to withdraw that consent at any time simply by contacting us as described in the subsequent section entitled “How we recognise your rights”.

What personal data we collect

Joy Limited typically collects the full range of standard personal identifying data sets from customers, and others, such as:

Name;
Postal address, email address, telephone numbers;
Social media and website addresses;
Business/organisation name and job title – where appropriate;
Standard employment related personal data – where appropriate.

We do not collect any sensitive data (as defined by Article 9 of the General Data Protection Regulation) from you as a customer; however, it can be necessary for the effective management of our employees. If such data are so needed, then we will put in place appropriate mechanisms to ensure their protection.

How we collect your personal data

Joy Limited collects personal data in one or more of the following ways:

By visiting our customers’ salons or by contacting our customers via phone or email;
By members of the public contacting us for details of their local salon stockist;
By our salon customers approaching us for more details of how to stock our products;
By salons registering on our website to become trade customers;
By maintaining business relationships with our suppliers, contractors, associates, and business contacts; and
Managing our relationships with our staff.

What we do with your personal data

Joy Limited uses the personal data it collects, processes and retains to:

Provide to its customers the paid goods and education services it has agreed to supply to them;
Invoice its customers for the goods provided;
Pay its suppliers for goods;
Meet its legal obligations as a private limited company; and
Market its own business.

What information we might share

If Joy Limited needs to work with third parties, such as product demonstrators, then they may have access to your personal data but only to the extent needed to do their work for us. If required to do so by law we may need to disclose your personal data to the police.

How we protect, store and dispose of your personal data

Joy Limited protects your personal data that it collects, processes, stores and retains by:

Employing a level of security at its facilities and on its equipment appropriate to the data protection risk;
Only using software products from reputable providers;
Carrying out all its banking activities via its on-line account;
Disposing of all confidential paper waste by using a specialist shredding contractor; and
Putting in place all reasonable organisational steps to ensure the integrity of such personal data.

How long we keep your personal data

Joy Limited will only keep your personal data for as long as one of the following apply:

You are an active customer;
You are an active supplier, contractor, associate, or other business contact;
We are required to do so by law;
You are an employee; or
We need that data to support our legitimate business interests, as explained above.

After you stop being an active customer, supplier, contractor, employee or other business contact, Joy Limited may keep your data longer for one of these reasons:

To maintain records so as to meet any legal obligations that apply to it; and
To try to resolve any issues that may arise, such as any queries or complaints.

Joy Limited will carry out a data cleansing exercise every year to remove any personal data that it no longer needs.

How we recognise your rights

As a data subject you have certain rights. If you wish to access any of these rights, then please send an email to customerservices@joyltd.co.uk

It would be helpful to use the heading “Subject Access Request” in the form’s “Subject” Field.

Or by writing to Joy Limited at:

Joy Limited

1 Holly Court

Tring Road

Wendover

HP22 6PE

Again, it would be helpful if you would mark your letter with the heading “Subject Access Request”.

How to complain

If you are unhappy with how Joy Limited has used your personal data please get in touch by writing to the email address outlined in the section above, or by writing to the address above. You also have the right to complain to the Information Commissioner’s Office, whose contact details are on their website:

https://ico.org.uk/concerns/

How we use your data to market our business

Joy Limited may wish to provide you with information about some of the products it provides or is planning to provide to its customers, or other recent and relevant developments. Joy Limited will only do so if it has your consent or it considers such an activity is in the legitimate interests of the development of its business. If Joy Limited does contact you on such a basis then it will always offer you the opportunity to tell it that you do not want to receive any further such information.

It is Joy Limited’s policy not to purchase marketing lists rather it will rely in this instance on the following sources of personal data:

Existing customers;
Our own research of potential salon customers and individual customers;
Details collected from enquiries made by potential customers.

The Joy Limited website uses cookies to see how many people visit the site and which pages are viewed and for how long, none of the information we gather via cookies identifies you as an individual – it is all entirely anonymous.

There may be links to other websites contained within the Joy Limited website pages and we are not responsible for the content and cookies they may use.

If you would like to find out more about what cookies are and do, please visit: http://www.whatarecookies.com/

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